Subject: File No. S7-14-08
From: Robert W. Rainey
Affiliation: Life Insurance Producer - MassMutual Life Ins. Co.

November 18, 2008

Indexed Annuities are not the same as Variable Life Insurance or Annuity contracts under which the insured has to select various sub-accounts (similar to mutual funds)and receive advise from the insurance agent on asset allocation to reach his or her investment goals. Therefore, the only application of "investment vehicles" are the Dow, SP 500 and NASDAQ used as indexes to allocate interest earned on the Indexed Annuity. I am opposed to classifying the Indexed Annuity as an investment product subject to SEC or NSDA regulations. I do have Series 63 and 6 certification to provide investment advise to clients.